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HEBRANK v. COMMISSIONER

Docket No. 24215-81.

81 T.C. 640 (1983)

STEVE A. HEBRANK, PETITIONER v. COMMISSIONER OF INTERNAL REVENUE, RESPONDENT

United States Tax Court.

Filed September 26, 1983.

Attorney(s) appearing for the Case

John F. Driscoll, for the respondent.

WILBUR, Judge:

Respondent determined a deficiency of $6,906.70 in the 1979 Federal income tax of petitioner Steve A. Hebrank, and also imposed an addition to tax under section 6653(b)1 of $3,453.35. The sole issue for our decision is whether any part of petitioner's underpayment in 1979 was due to fraud.2

FINDINGS OF FACT

Petitioner Steve A. Hebrank lived in Riverview, Fla., when the...

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